Seth Shapiro v. AT&T Mobility, LLC

IN THE UNITED STATES DISTRICT COURT

FOR THE CENTRAL DISTRICT OF CALIFORNIA

SETH SHAPIRO, Cas e No. 2:19-cv-08972-CBM (RAOx) 5 Plaintiff, STIPULATION AND PROPOSED 6 vs. PROTECTIVE ORDER 7 AT&T MOBILITY, LLC, et al.,

Defendants. 10 11 1. PURPOSES AND LIMITATIONS Discovery in this action is likely to involve production of confidential, proprietary or private information for which special protection from public disclosure and from use for any purpose other than pursuing this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. 2. GOOD CAUSE STATEMENT This action is likely to involve trade secrets,…